ML20063P466

Responds to NRC Re Violations Noted in IE Insp on 820401-30.Corrective Actions:Local Grinding Conducted to Expose Weld Root & Base Metal Surfaces.Partial Penetration Butt Weld Undersized

ML20063P466
Person / Time
Site:	Washington Public Power Supply System
Issue date:	09/09/1982
From:	Root R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Bishop T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20063P450	List: ML20063P459 ML20063P466
References
GO1-82-0549, GO1-82-549, NUDOCS 8210130432
Download: ML20063P466 (7)

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'.4 TO Washington Public Power Supply System Of es P.O. Box 968 3000 GeorgeWashingtonWay Richland, Washington 99352 (509)372?5000 September 9, 1982 U-G01-82-0549 N

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Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Attention: Mr. T. W. Bishop, Chief Reactor Construction, Projects Branch

Subject:

NUCLEAR PROJECTS NOS. 1/4 NRC INSPECTION WNP-1/4 DATES OF INSPECTION APRIL 1-30, 1982 D0CKET NOS. 50-460, 50-513 CONSTRUCTION PERMIT NOS. CPPR-134, CPPR-174

Reference:

Letter, R.H. Faulkenberry to R.W. Root, dated June 8,1982, NRC Inspection at WNP-1/4 Site The above reference letter delineated the results of the April 1-30, 1982 inspection of activities authorized by NRC Construction Permit Nos.

CPPR-134/174.

Further, the referenced letter identified certain activities which were not conducted in full compliance with NRC requirements set forth in the Notice of Violation enclosed as Appendix A.

These items of noncompli-ance have been categorized into a level as described in Supplement II of the Federal Register dated October 7, 1980 (45FR66754) as the Interim Enforcement Policy.

The specific findings, as identified, and the Supply System responses are provided herewith as Appendix A.

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j R. W. Root, Jr.

Acting Program Di ector, WNP-1/4 djs cc: Mr. C. R. Bryant - Bonneville Power Administration (399)

Mr. J. P. Laspa, Bechtel Power Corporation (860)

Mr. V. Mani - United Engineers & Constructors, Inc. (897)

Mr. V. Stello, Director of Inspection, NRC Mr. A. Toth, Nuclear Regulatory Connission l

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R. 'W. Roct,-being first duly' sworn, ' deposes a'nd saysh 'Tha't he is' the

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Acting Program Director, WNP-1/4, for the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the applicant herein;.that he is, authorized to submit the fore-going on; behalf of,said applicant;Ithat he'has read the foregoing and knows the contents thereof: 'and believes the same to be true to the be'st of his knowledge.

DATED.

M, 1982

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R/ W.W On this day personally appeared before me R. W. ROOT-to me known to be the individual who executed the' foregoing instrument and acknowledged that he signed the same.as his free act and deed for the uses and pur-poses therein mentioned.

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GIVEN under my hand and seal this ay of (a d

, 1982 OroY CLC NotaryPubNc'inkdjfortheState of Washington Residing at TAs/Jd

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' NUCLEAR REGULATORY-COMISSION REGION V 1450 MARIA LANE SUITE 210 WALNUT CREEK, CALIFORNIA 945%

DOCKET NO. 460 AND 50-513 CONSTRULiION PERMIT NO. CPPR-134 AND -174 Appendix A A.

_10 CFR 50 Appendix B Criterion V, as addressed in paragraph 17.4.5 of the Quality Assurance' Program _ in Section 17 of the-PSAR, states in _ part:. '" Activities affecting-quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings..."

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a.

Detail B-B of the project design drawing F435860 requires a partial penetration weld of 3/4-inch size, for the Tee-joint connection of members #2 and #3 of pipe rupture-restraint MSS-PW-3-2.

Contrary to the above,- on April 19, 1982 the completed, inspected, and accepted restraint MSS-PW-3-2, furnished by -

Corner and Lada Company, contained a partial penetration weld i

of 7/16-inch. size along 10-inches of the accessible length of one Tee-joint weld.

This is a Severity. Level V Violation (Supplement II),

applicable to Unit 1.

i b.

Foley-Wismer-Becker procedure QCP-5A requires' that "All. welds will be documented on Weld Inspection records".

This i

procedure. was reviewed and approved by the licensee's representative, in accordance with the quality assurance

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program.

It provides reference to weld inspection criteria.

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Contrary to the above, in mid-February the inspectors for -

Foley-Wismer-Becker ceased to preparc the required records, i

and had alternatively instituted practices of an internal

• instruction QCI-98.

The required Weld Inspection Sheets were not prepared for conduit' supports 1C 30H-3418-ADA and IC 30H-3418-ADB.

I-This is a Severity Level V Violation (Supp1'ement II),

applicable to Unit 1.

j c.

The. Preliminary Safety Analysis Report Section 3.12 states that. quality assurance requirements for storage and handling of-items of WNP-1 will conform to the regulatory position of Regulatory Guide 1.38, which involves ANSI-N45.2.2-1972. The implementing Bechtel WNP-1/4 Nuclear Quality' Assurance Manual Section IV_ Number. 2 requires that " Receiving, controlling, 1

storing, maintaining of material and equipment meet the applic-able requirements-of applicable drawings and specifications, supplier's requirements and ANSI-N45.2.2."

The ANSI-N45.2.2 Parts 1.2 and 6.5 require protection of equipment from deteriora-tion during storage and installation.

The Equipment Maintenance procedure WP/P-4 Section A13.1 requires that Bechtel

" Implement the Project Preventive Maintenance Program on all stored equipment." and "...on equipment in the site Contractor's custody."

Contrary to the above, the preventive maintenance program was not fully implemented on all equipment in the contractors' custody, such that:

(1) By March 1982 the protective measures had been insufficient to prevent rusting and physical damage to machined flange faces on containment encapsulation vessels DHR-VSL-1 A and 28 for decay heat removal system valves. The equipment was in custody of the J. A. Jones Company.

(2) By April 1982 the protective measures had been insufficient to prevent accumulation of metal shavings and other fine debris in 13800/480 volt switchgear identified as 1-APN-USS-0EB1-B.

This equipment was in the custody of the Foley-Wismer-Becker Company.

This is a Severity Level V Violation (Supplement II), applicable to Unit 1.

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A.(a) SUPPLY SYSTEM RESPONSE Corrective Action Taken On April 19,

1982, Bechtel Quality Control issued Bechtel Nonconformance Report No.

1-BNCR-151-2, which identified an apparent undersized weld on pipe rupture restraint MSS-PW-3-2.

UE8C has examined the weld in question as well as three other welds on the same support which have been specified to an identical configuration.

The examination has consisted of local grinding to expose weld root and base metal surfaces.

Exposure by grinding of the four welds shows that the partial penetration butt weld preparation is undersized.

However, an acid etch to identify the weld deposit and joint configuration will be completed.

Etching will provide more accurate information.

Based upon weld configuration data obtained, UE&C will recalculate pipe restraint loads to assure that the ability of the restraint to function as designed has not

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been compromised.

Any functional inadequacy will be identified during this review.

Within 30 days of this report. disposition of the MSS-PW-3-2 non-conformance will be completed.

An outline of any further investigative actions planned will also be completed and forwarded no later than September 24, 1982.

Corrective Action to Preclude Recurrence Since all the pipe rupture restraints have already been fabricated and received at the WNP-1/4 jobsite, corrective action by the vendor to preclude recurrence is not possible.

Date of Full Compliance Due to the investigative actions yet to be completed, the date of full compliance will be provided in the September 24, 1982 report.

A.(b) SUPPLY SYSTEM RESPONSE Corrective Action Taken On April 15, 1982, Bechtel QC required Foley-Wismer & Becker (FWB) to stop all installation of conduit and conduit supports in accordance with QCI-98.

This stop work remained in effect until the contractor had resolved the deficiencies between QCI-9B and the Engineer approved QCP's (including QCP-5A).

The contractor elected to delete QCI-98 and utilize the approved QCP's for the installation and inspection of conduit and supports.

This action was completed by April 16, 1982.

Conduit support installations and inspection which were completed from April 16, 1982 until May 21,1982 (last day of craft work at WNP-1) were accomplished to the requirements of approved QCP's. -.

r In addition, contractor nonconformance reports 1-CNCR-218-1100 &

1110 were written on May 19, 1982 to document the work which was completed from December 1981 through April 15, 1982 in accordance with QCI-98.

These CNCRs were submitted to the Engineer for dispositioning. Closeout of CNCRs by the contractor will be based on the Engineers disposition.

Corrective Action to Preclude Recurrence All other FWB QCI's were reviewed by the contractor to assure compliance with the requirements of approved QCPs.

All FWB personnel involved in field routing of conduit including engineers, inspectors and supervisors down to the foreman level were given a training session on April 19-20, 1982. These training sessions included the use of the Wold Inspection Sheets which is required by QCP-5A.

Date of Full Compliance The above noted corrective actions have been completed.

The effectiveness of the corrective actions taken cannnot be fully verified until construction activities are resumed at WNP-1.

A.(c) SUPPLY SYSTEM RESPONSE Corrective Action Taken A Maintenance Work Order (MWO) No. CA 2246 was prepared on May 11, 1982 for the purpose of cleaning, taping and identifying switchgear cabinet 1-APN-USS-0EB-1B. Additional MW0s and Mainten-ance Work Requests were prepared for the remaining Class IE switchgear cabinets to perform identical preventive maintenance.

The flanges of the Isolation Valve Encapsulation Vessels DHR-VSL-l 1A & 2B were examined by Bechtel Quality Control and rework was l

deemed necessary.

This examination was performed on April 14, 1982 and is documented on Surveillance Report No. 257-S-3.00. The l

mechanical contractor, (JA Jones) initiated Inspection Report Nos.

6604, 6339 and 6640, which details rework that needs to be performed.

It has been determined by Bechtel Contract Coordinat-ion and concurred with by UE&C Engineering that the required rework be performed upon construction restart.

Postponing the rework will not result in further deterioration of the flanges.

Action to Preclude Recurrence As of July 1,1982, the Supply System assumed responsibility for the Preventive Maintenance program which will be administered by the Plant Manager through the Maintenance Manager.

Preventive Maintenance (PM) activities, are scheduled on a monthly basis l

utilizing task cards which detail PM work to be performed. During the conduct of specific PM activities, the surrounding areas will l

be examined and any additional housekeeping required will be performed by utilizing Maintenance Work Orders / Requests.

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F The Construction Management Organization (CM0) has notified the varicus site contractors by letter informing them of their responsibilities when working on an item.

Specifically, when a contractor works on equipment he shall replace covers, store parts in such a manner to prevent deterioration when disassembling equipment, clean up construction debris, continue QC/QV surveil-lance and notifies the CMo when a problem exists which requires action by the PM Organization.

Project Quality Assurance will perform periodic surveillances of the Preventive Maintenance program and general housekeeping to assure compliance with approved procedures.

Date of Full Compliance Due to the WNP-1 extended construction delay, completion of all the above noted corrective actions is indeterminate, and the effectiveness of the corrective actions taken cannot be fully verified.

The Supply System will include the specific item related with the flanges in the Project follow-up status listing of comitments requiring action prior to or upon resumption of construction activities.

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